NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute,
standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular
circumstances, but they cannot create additional employer
obligations. This letter constitutes OSHA's interpretation of
the requirements discussed. Note that our enforcement guidance
may be affected by changes to OSHA rules. Also, from time to time
we update our guidance in response to new information. To keep
apprised of such developments, you can consult OSHA's website
athttp://www.osha.gov.

June 3, 2005

MEMORANDUM FOR:

CHARLES ADKINSRegional Administrator

FROM:

RUSSELL B. SWANSONDirector, Directorate of Construction

ATTN:

BRIAN DRAKESafety Manager, Region VII

SUBJECT:

Alternative procedures under STD 03-00-001 (formerly STD 3-0.1A) for employees performing roofing work on roof slopes of 6 in 12 or less during residential construction.

This is in response to Mr. Drake's e-mail dated April 13,
2005. You ask a question regarding the installation of slide
guards under STD 03-00-001.

We have paraphrased your question as follows:

Question: Scenario: Employees are installing
weatherproofing materials (tar paper and shingles) on roof slopes
of 6 in 12 or less during residential construction covered under
STD 03-00-001. Employees cover the entire roof with tar paper
without slide guards installed. Then, the employees apply three
rows of shingles along the eave. Only after applying these three
rows, do the employees install the slide guards. Does this meet
the alternative fall protection measures of STD 03-00-001?

Answer: No. STD 03-00-001 states:

I. PURPOSE
* * *
B. Fall protection requirements for residential construction are
set out in 29 CFR 1926.501(b)(13). In general, that provision
requires conventional fall protection for work at or over six
feet. However, OSHA Instruction STD 3.1 modifies those
requirements. It permits employers engaged in certain residential
construction activities to use alternative procedures routinely
instead of conventional fall protection. No showing of
infeasibility of conventional fall protection is needed before
using these procedures...Different alternative procedures are
specified for different activities.
* * *
XII. ALTERNATIVE PROCEDURES FOR GROUP 4: ROOFING WORK
(REMOVAL, REPAIR, OR INSTALLATION OF WEATHERPROOFING ROOFING
MATERIALS SUCH AS SHINGLES, TILE, AND TAR PAPER).
Restriction on Application for Roofing Work. The alternative
procedures in this Instruction may only be used for this work
where: (a) the roof slope is 8 in 12 or less, and (b) the
fall distance, measured from the eave to the ground level, is 25
feet or less.
* * *
C. Slide Guards: Requirements for Materials, Configuration and
Installation.

1. Roof Slope: 6 in 12 or less:
* * *
b. Installation. No more than three rows of roofing material
(installed across the lower eave) shall be applied before
installing the slide guards. The roof jacks (or similar supports)
shall be installed using nails long enough to withstand an
employee sliding into the guard.

In the situation you describe above, employees have applied tar
paper to the entire roof without installing slide guards. The
alternative procedures permitted in STD 03-00-001 (XII)(C)(1)(b) do
not include this practice; it states: "No more than three
rows of roofing material (installed across the lower eave)
shall be applied before installing the slide guards"
(italics added). As noted in the heading to the "Alternative
Procedures to Group 4," tar paper is considered a
type of roofing material. Therefore, an employer who applies more
than three rows of tar paper on a 6 in 12 or less roof without
installing slide guards is not in compliance with STD 03-00-001
(XII)(C)(1)(b).

You also note that OSHA, in a letter to Mr. Todd Hoffmann on
November 17, 2003, stated that:

No fall protection is required under STD 03-00-001 while
employees lay the initial three rows of material; it is only
required to install slide guards after the installation of the
first three rows of shingles (italics added).

You ask if this language permits employers to apply tar paper to
an entire roof without installation of slide guards because at
that point, the first three rows of shingles have not been
installed. The Hoffman letter does not stand for such a
proposition. The incoming Hoffmann letter focused primarily on
the application of the first three rows of shingles and,
therefore, the Agency was specifically addressing Mr.
Hoffmann's question about shingles, not "roofing
material" in general.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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